Getting to the Finish Line: Best Practices & War Stories - Oct. 22nd, 2026

This program is part of AAA’s inaugural Mediation Month, a centennial celebration centered on the theme “The Final Mile of Mediation.”

Location: Houston, TX

South Texas College of Law Houston
1303 San Jacinto Street
Houston, TX 77002

Time: 3:00 p.m. - 6:00 p.m. (Central Time)

Registration Fees: General: $125.00. AAA Mediators receive a $30.00 discount using 26MED001 at checkout. 

Program Description:

The final hours of a mediation are where deals are made — or lost. As fatigue sets in, positions harden, and the easy concessions have already been spent, mediators and counsel find themselves navigating the hardest part of the day: getting the parties across the finish line. This panel of experienced Houston mediators will share best practices, candid war stories, and practical strategies drawn from thousands of mediations for managing the critical last third of the process.

The discussion will cover techniques for breaking impasse (mediator's proposals, bracketing, decision-tree analysis, and the well-timed reality check); drafting settlement agreements that hold up under pressure (Rule 11 agreements, term sheets, MOUs, enforceability traps, and the mediator's appropriate role in the drafting process); diagnosing and avoiding settlements that fall apart after the parties leave the room; and creative alternatives when conventional settlement is out of reach, including binding mediation, baseball and high-low arbitration, issue arbitration, and other tools to bring about resolution.

Attendees will leave with concrete techniques for moving stuck parties to resolution, a deeper appreciation of the mediator's role in the closing hours, and a broader toolkit of options to bring disputes across the finish line.

Moderator: 

Iman Hyder-Eliz, AAA Vice President

Faculty:

Felicia Harris Hoss, AAA Mediator and Arbitrator
Michael Hawash, AAA Mediator and Arbitrator
Jerry Hoover, AAA Mediator and Arbitrator

CLE Information:

Cerifi LegalEdge is coordinating the application process for continuing legal education (CLE) credit on behalf of the American Arbitration Association. CLE credit has been requested in Texas. 

Approval and credit amounts are subject to each jurisdiction’s review and rules and therefore cannot be guaranteed or confirmed in advance. Final credit eligibility will be determined by the respective state CLE authorities upon review of the program and verified attendance.

AAA Education Scholarships Available:

As part of its long-standing, ongoing education mission, the American Arbitration Association grants a limited number of scholarships that cover the cost of educational program registration for content on this website. To inquire about our scholarship program, please e-mail us at Scholarships@adr.org.

Cancellation Policy:

Refunds (less a $25 processing fee) are available if a written cancellation request is received no later than 14 business days before the start of the program. Substitution of attendees can be made at any time.